Mauritius GBC1 Companies will be liable to tax rate of 15% from 1 Jan 2019

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As of 1 January 2019, GBC1 companies will be renamed as Global Business Licence (GBL) and will be liable to tax at the rate of 15%. However, GBL will qualify for an exemption of 80% of the specific foreign-source income (e.g. foreign dividend not allowed as deduction in source country, foreign interest income, foreign-source income derived by a Collective Investment Scheme [CIS], closed end funds, CIS manager, CIS administrator, investment adviser or asset manager licensed or approved by the FSC, and income derived by companies engaged in ship and aircraft leasing).

GBL will qualify for an exemption of 80% of the specific foreign-source income

No actual foreign tax credit is allowed on foreign-source income if the GBL company has claimed the 80% exemption.

Exemption to Freeport companies (excluding local trading activity) shall continue to apply until 30 June 2021 to any company issued with a Freeport certificate on or before 14 June 2018.

ENTITY

TAX RATE (%)

Global Business Category 1 (GBC1) companies (Global Business Licence as of 1 January 2019) except for specific income

15

Freeport operators or Private Freeport Developers carrying on Freeport activities other than providing goods and services on local markets

15

Global Business Category 2 (GBC2) companies

Exempt

Companies engaged in the export of goods

3

All other companies

15

GBC 2 LICENCES

As of 1 January 2019, GBC2 licence will be abolished.

Companies conducting business and having their place of effective management outside of Mauritius will be required to apply for an authorisation to the FSC to be registered as an ‘Authorised Company’.

After 31 December 2018 or 30 June 2021, as applicable (see below), GBC2 licences will lapse and companies should continue to comply with the prescribed requirements of the FSC.

An Authorised Company will be treated as a non-resident for tax purposes in Mauritius.

An Authorised Company is required to file a return of income to the MRA within six months of its year-end.